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CMS Issues Instructions Related to the Submission of HIPPS Codes to Report Medicare Advantage Encounters

Dan Ciolek

On September 26, 2019, the Centers for Medicare and Medicaid Services (CMS) issued updated guidance to Medicare Advantage (MA) plans regarding encounter data coding requirements associated with the implementation of the Payment Driven Payment Model (PDPM) on October 1.  The document, titled “Updated Information on Submission of Health Insurance Prospective Payment System (HIPPS) Codes to Medicare Advantage Encounter Data System – September 2019” is available to AHCA members here.

Providers should consider the following statements from the guidance that may be useful in conversations with MA plans about how CMS is providing flexibilities about whether to report legacy RUGs-based HIPPS codes or PDPM-based HIPPS codes to report MA encounters for dates of service starting October 1, 2019.      

“In order to allow providers and Medicare Advantage Organizations (MAOs) maximum flexibility in the submission of HIPPS codes on encounter data, CMS will accept the existing HIPPS codes as well as the new HIPPS codes.

• SNF encounters with “from” dates on or after October 1, 2019 and HH encounters with “from” dates of service on or after January 1, 2020 may be submitted using the existing HIPPS codes or the new HIPPS codes.”

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